Cynthia Emery Weight - Page 1

                                        T.C. Memo. 2003-214                                             

                                     UNITED STATES TAX COURT                                            

                              CYNTHIA EMERY WEIGHT, Petitioner v.                                       
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 6932-01.              Filed July 16, 2003.                                 

                  Jan R. Pierce, for petitioner.                                                        
                  Robert V. Boeshaar, for respondent.                                                   

                                        MEMORANDUM OPINION                                              

                  DAWSON, Judge:  This case was assigned to Special Trial                               
            Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) and Rules                           
            180, 181 and 183.1  The Court agrees with and adopts the opinion                            
            of the Special Trial Judge, which is set forth below.                                       

                  1  Section references are to the Internal Revenue Code of                             
            1986, as amended.  Rule references are to the Tax Court Rules of                            
            Practice and Procedure.                                                                     

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